Association of Data Processing Service Organizations, Inc. v. Camp
In Association of Data Processing Serv. Orgs. v. Camp, 397 U.S. 150, 90 S.Ct. 827, 25 L.Ed.2d 184 (1970), the Supreme Court found sufficient injury-in-fact under Article III because the petitioners experienced increased competition for their customers as a result of the challenged government action.
The Supreme Court held that the petitioners, data processing service providers, had standing to challenge a ruling by the Comptroller of the Currency that authorized national banks to provide data processing services to other banks and to bank customers because the petitioner "not only alleged that competition by national banks in the business of providing data processing services might entail some future loss of profits for the petitioners, they also alleged that respondent American National Bank & Trust Company was performing or preparing to perform such services for two customers for whom petitioner Data Systems, Inc., had previously agreed or negotiated to perform such services." 397 U.S. at 152, 90 S.Ct. 827.
In Association of Data Processing Service Organizations, Inc. v. Camp, 397 U. S. 150 (1970), the association challenged a ruling by the Comptroller allowing national banks, as part of their incidental powers under 12 U. S. C. 24 Seventh, to make data-processing services available to other banks and to bank customers.
There was no serious question that the data processors had sustained an injury in fact by virtue of the Comptroller's action. Rather, the question, which the Court described as one of standing, was whether the data processors should be heard to complain of that injury.
The matter was basically one of interpreting congressional intent, and the Court looked to 10 of the Administrative Procedure Act (APA), 5 U. S. C. 702, which "grants standing to a person `aggrieved by agency action within the meaning of a relevant statute.' " (397 U. S., at 153.)
The Court of Appeals had interpreted 702 as requiring either the showing of a "legal interest," as that term had been narrowly construed in our earlier cases, e. g., Tennessee Electric Power Co. v. TVA, 306 U. S. 118, 137 (1939), or alternatively as requiring an explicit provision in the relevant statute permitting suit by any party "adversely affected or aggrieved."8 See Association of Data Processing Service Organizations, Inc. v. Camp, 406 F. 2d 837 (CA8 1969).
The Supreme Court was unwilling to take so narrow a view of the APA's " `generous review provisions,' " 397 U. S., at 156 (quoting Shaughnessy v. Pedreiro, 349 U. S. 48, 51 (1955)), and stated that in accordance with previous decisions the Act should be construed "not grudgingly but as serving a broadly remedial purpose," ibid. (citing Shaughnessy, supra, and Rusk v. Cort, 369 U. S. 367, 379-380 (1962)).
Accordingly, the data processors could be "within that class of `aggrieved' persons who, under 702, are entitled to judicial review of `agency action,' " 397 U. S., at 157, even though the National Bank Act itself has no reference to aggrieved persons, and, for that matter, no review provision whatsoever.
It was thought, however, that Congress, in enacting 702, had not intended to allow suit by every person suffering injury in fact. What was needed was a gloss on the meaning of 702.
The Court supplied this gloss by adding to the requirement that the complainant be "adversely affected or aggrieved," i. e., injured in fact, the additional requirement that "the interest sought to be protected by the complainant be arguably within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question." Id., at 153.
The Court concluded that the data processors were arguably within the zone of interests established by 4 of the Bank Service Corporation Act of 1962, 76 Stat. 1132, 12 U. S. C. 1864, which forbids bank service corporations to "engage in any activity other than the performance of bank services for banks." See 397 U. S., at 155.
In so holding, the Court relied on a brief excerpt from the legislative history of 4 indicating that Congress intended to enforce adherence to "the accepted public policy which strictly limits banks to banking." Ibid.